500 Fifth Avenue, 40th Floor New York, NY 10110 tel: 212-257-48B0 tax:212-202r6417 •Jr.. sa Shapiro Arato LLP ' www.shapiroarato.com O.Tiq ! r, .- . r,-, Alexandra A.E. Shapiro 1 r: / [email protected] Direct; 212-257-4881 ClrPICr June 18,2015
VIA HAND DELIVERY
Office of the General Counsel Federal Election Commission 999 E Street, N.W. MUR# Washington, D.C. 20463
Re: MUR 6869, In the Matter of the Commission on Presidential Debates, et al.
To Whom It May Concern:
We represent the Libertarian National Committee, Inc., which controls and manages the affairs of the United States Libertarian Party (the "Libertarian Party"). On its behalf, we respectfully request to join the Complaint against the Commissiori on Presidential Debates and certain of its directors, filed on behalf of Level the Playing Field and Peter Ackeiman In the Matter of the Commission on Presidential Debates, et al, MUR 6869. The Libertarian Party shares the views of Level the Playing Field and Dr. Ackerman that the Commission on Presidential Debates ("CPD") and certain of its directors (the "Named Directors") have violated the Federal Election Campaign Act and the Commission's regulations in connection with the CPD's hosting of general election presidential debates.
The Libertarian Party asserts no new allegations, and instead incorporates fully the allegations against the CPD and the Named Directors set forth in the Complaint in MUR 6869. Accordingly, the Commission should permit the Libertarian Party to join the Complaint in MUR 6869 rather than initiating a new MUR and treating the Libertarian Party's request to join as a new administrative complaint.
With this letter, please find one original and three copies of the Libertarian Party's Complaint and Request to Join Complaint in MUR 6869, as well as four copies of the Complaint in MUR 6869 and its two accompanying volumes of exhibits, and a DVD containing electronic copies of these documents.
Please contact me if the Commission has any questions or needs additional information. We hope that the Commission will move expeditiously to address our request to join the Complaint, as well as to address the matters raised in the Complaint. Sincerely,
Alexandradra A:i£AM. Shapiro'.Shapirb' End.
cc: Kim Collins, Office of Complaints Examination and Legal Administration (via e-mail)
5 Q BEFORE THE FEDERAL ELECTION COMMISSION
the Matter of o -n era Commission on Presidential Debates, ... I ci M Frank Fahrenkopf, Jr., Michael D. McCurry, •r-Ji-i Howard G. Buffett, John C. Danforth, John Griffen, Antonia Hemaiidez, John I. Jenkins, Newton N. Minow, , n- Richard D. Parsons, Dorothy Ridings, Alan K. Simpson, and Janet Brown ro* • Z': c i MUR # MA-Z- I REOUEST TO JOIN COMPLAINT IN MUR 6869 OR COMPLAINT
SHAPIRO ARATO LLP 500 Filth Avenue 40th Floor New York, New York 10110 Phone: (21.2)257-4880 Fax: (212)202-6417
Allorneys for Complainant Libertarian National Committee, Inc. Complainant Libertarian National Committee, Inc., which, controls and manages the affairs of the United States Libertarian. Party (the "Libertarian Party"), joins the Complaint of
Level the Playing Field and Peter Ackerman filed before the Federal Election Commission In the
Matter of Commission on Presidential Debates, et al, MU.R 6869 (the "Complaint"). The
Libertarian Party shares the views of Level the Playing Field and Dr. Ackerman that the
Commission on Presidential Debates ("CPD") and certain of its directors, in connection with tlieir hosting of general election presidential debates, have violated the Federal Election
Campaign Act and the regulations of the Federal Election Commission, for the reasons set forth in detail in the Complaint, which are incorporated by reference as if fully set forth herein. See 52
U.S.C. §§ 301.18(a), 30116(i),,30103, 30104; 11 C.F.R. § 110.13.
The Libertarian Party is the third largest political party in the coutitry. Its address is 1444
Duke Street, Alexandria, VA 22314.
Founded in 1971, the Libertarian Party has nominated presidential candidates during every presidential election since its formation, including Ed Clark in 1980, who appeared on the ballot of all 50 states and the District of Columbia; David Bergiand in 1984, who received the third greatest number of votes in the presidential election; Ron Paul in 1988, who was on the ballot in 46 states and the District of Columbia and received the third most voles in the presidential election; Andre Marrou in 1992, who was on the ballot of every state and the District of Columbia; Flarry Browne in 1996, who was on the ballot of every state and the District of
Columbia - the first time in United States history a "third party" earned ballot status in all 50 states and the District of Columbia for a second consecutive time; Harry Browne again in 2000, who headed a ticket of 1,436 Libertarian Party candidates, including 256 candidates for the U.S. House of Representatives; Michael Badnarik in 2004, who was on the ballot in 48 states; Bob
Barr in 2008, who led a ticket iri.an election in which fifty Libertarians were elected, or re elected; and Gary Johnson in 2012, who received 1,275,951 votes, in an election during which six of the Libertarian Party candidates for office also received, a total of over one million votes.
Libertarian Party presidential candidates, including Governor Johnson in 2012, have been
excluded from all general election presidential debates since the CPD adopted the selection
criteria challenged in the Complaint:.
.For the reasons set forth in the Complaint of Level the Playing Field and Peter Ackerman
In the Matter of the Commission on Presidential Debates, et al, MUR 6869, the Libertarian
Party respectfully requests that the F.EC find the CPD and its directors have violated the Federal
Election Campaign Act and the regulations of the Federal Election Commi ssion, and grant the relief sought in the Complaint.
Dated this ft+^day of June, 2015. Respectfully submitted,
Libert^an National dpmrniti^, Inc. By: Robert C.W. Benedict, Jr., Executive Director
Signed and sworn to before me this 1 ^ day of June, 2015
ROBERT STEVEN KRAUS Notary Public Commonwealth o» Virginia 7514213 My Commission F*p-
Notary Public 1 S] H-Zy I 3